CARES Act: Medicare COVID-19 Prepayment Program FAQs

Updated April 6, 2020

The Centers for Medicare & Medicaid Services (CMS) released information on the new availability of advance payments to physicians to help during the COVID-19 emergency within 24 hours of receiving expanded authority under the CARES Act . The rapid roll-out of the program has led to questions about how to obtain the funds and the conditions that may be attached to them. The following responses are based on WADA’s discussions with senior CMS officials. WADA will continue to work with CMS to try to improve the program.

  1. Advance payments are supposed to be requested from the doctor’s Medicare Administrative Contractor (MAC), but each MAC has its own form. The forms are confusing and it is difficult to know how to respond to the requested financial information.
    Down payments are not new, but they have only rarely been used. Because the COVID-19 prepayment program was rolled out so quickly, CMS let MACs use the claim forms they had previously used. That said, CMS understands that application forms are confusing. He is discussing the forms with the MACs and a more standardized form could be developed. For COVID-19 prepayment requests, medical offices do not need to answer financial questions on the forms, such as anticipated receipts, expenses, and cash flow. The most important information required is that the request is based on the COVID-19 emergency and the signature of an authorized person. Specifically, doctors are to declare that “they are having cash flow issues due to the COVID-19 crisis.”
  2. How do physicians complete the amount requested portion of the form? What is 100% of the 3 months Medicare payment?
    Doctors do not need to calculate these amounts themselves. All CMAs have been instructed to use physician reimbursement requests for the period October-December 2019 as the basis for the maximum amount of the advance payment. (Currently there are no exceptions for special circumstances such as a doctor who was on leave between October and December 2019.) Doctors can also choose to request less than 100% of the 3-month payment. they want it. A doctor who asks for 50% of the maximum can come back later and ask for the remaining 50%.
  3. How does the clawback process work and will interest be charged?
    Based on the law, the collection of down payments will begin 120 days after the funds have been disbursed, and they will be taken from claims submitted at that time until the full amount has been repaid. Doctors can request to reimburse the funds, or part of the funds, directly instead of recovering them through claim submissions. Physicians can also request that payments be made on less than 100% of claims during the reimbursement period. No interest is charged on COVID-19 prepayments which are repaid within 210 days of disbursement. If reimbursement within this timeframe is a constraint on the practice, physicians may request that the MAC provide an extended reimbursement plan; however, interest is charged on payments from the 10.25% extended repayment plan.
  4. CMS’s prepayment notice says physicians cannot be eligible if they are under an active medical review or program integrity investigation. Does Targeted Probe and Education (TPE) count as a medical exam? Validation of registration?
    No, the types of investigations that would prevent a physician from receiving advance payments are program integrity and fraud investigations. VSEs do not count, nor do RAC audits. Physicians under investigation will have received notification from a program integrity contractor.
  5. Can a group practice request prepayment using their TIN, or must each physician request it?
    Prepayments should be requested at the level of each NPI, as this is how MACs calculate the amount of payments to be made. If everyone in a group wants to request a deposit, each doctor will need to fill out a form with their NPI. Payments will be made the same way as other Medicare payments, so if the group’s claims are paid to a particular TIN, this is where the prepayment will go.
  6. Will the remittance notice explain when the doctor’s future demands will be reduced to repay the advance?
    Yes.
  7. The CMS fact sheet states that there is no administrative right of appeal. What does it mean?
    The CMAs determine if the physician is eligible for the advance payment and the amount for which he is eligible; these decisions are not subject to appeal. Physicians can always resubmit and / or appeal individual requests that are denied.

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